The approach adopted by the Applicant towards AONB planning policy betrays a fundamental misunderstanding of the purpose of paras 115 and 116 of the NPPF. It is clear from the Framework that major development in an AONB should be regarded as damaging per se. Para. 115 states that “Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.”

Any major industrial development in an AONB must therefore be regarded as wholly inappropriate and undesirable in such a designated area, thus the requirement of meeting not just the threshold of exceptionality, but also (wholly unaddressed by the Applicant) that of demonstrating that such development is in the public (as opposed to private) interest.

The proposal at Blackhill Quarry represents an extension of damaging, adverse industrial development in the AONB. Current permitted processing operations at the site are subject to strict controls in respect of being both time limited and subject to agreed restoration requirements. The proposal to prolong operations and consequently delay restoration in the AONB is wholly contrary to Framework principles and policies, and, if permitted, would represent development at its most unsustainable.

Silica sand is considered to be... of national importance due to its limited distribution.78

... I am satisfied that that there is a need for the development and that there are currently no viable alternatives if the provision of washed, graded and dried silica sand is to be met in Kent and the South East. I am also satisfied that if new reserves are not permitted at Wrotham it is likely that there would be adverse impacts on the supply of silica sand nationally... In view of this, I am further satisfied that the application meets the “exceptional circumstances” and “public interest” tests required by paragraph 116 of the NPPF.96

… in the absence of “exceptional circumstances” and “public interest” being demonstrated in the context of need and alternatives I would be unable to support the application. However, for the reasons set out elsewhere in this report, I consider that these requirements have been satisfactorily met.128

AI cannot claim that if processing did not take place at Blackhill there would be national consequences - especially when it already owns an alternative site 6 miles closer and not in an AONB. Neither is there anything particularly special or scarce or of national importance about the sand and gravel at Straitgate - especially when AI already has millions of tonnes with planning permission just up the M5.